31
Dec
2025
Legal news
Banking and financial law
Companies and taxation
International and European law
2025
Legal news
Banking and financial law — Companies and taxation — International and European law
Automatic exchange of information (financial accounts): Addendum to the Multilateral Agreement between Competent Authorities (Sovereign Order No. 11.639 of 27 November 2025)
Sovereign Order No. 11.639 of 27 November 2025 (JDM No. 8776 of 5 December 2025) implements the Addendum to the Multilateral Agreement between Competent Authorities (CRS MCAA) which aligns with the consolidated text of the standard for the automatic exchange of financial account information established by the Organisation for Economic Co-operation and Development (OECD) in 2022/2023 (Common Reporting Standard, hereinafter "Consolidated CRS"), enforceable as of 1 January 2026.
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The Addendum adds certain information to the scope of exchanges under the CRS MCAA in order to take into account the additional reporting requirements introduced by the consolidated CRS, which has modified its scope and strengthened reporting requirements and due diligence procedures:
- whether a valid self-certification has been provided for each Account Holder;
- the role(s) by virtue of which each Reportable Person that is a Controlling Person of an Entity Account Holder is a Controlling Person of the Entity and whether a valid self-certification has been provided for each such Reportable Person;
- the type of account, whether the account is a Preexisting Account or a New Account and whether the account is a joint account, including the number of joint Account Holders; and
- in the case of any Equity Interest held in an Investment Entity that is a legal arrangement, the role(s) by virtue of which the Reportable Person is an Equity Interest holder.
In addition to this additional information to be reported, the consolidated CRS extends the automatic exchange of tax information to new digital financial instruments, treating certain crypto-assets, electronic money products and central bank digital currencies (CBDCs) as reportable accounts or financial assets. It is coordinated with the new Crypto Asset Reporting Framework (CARF) to cover all digital financial uses while avoiding double reporting.
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For more information on the content of the consolidated CRS, see our publication Automatic Exchange of Information (Financial Accounts) • Amending Protocol of 13 October 2025 to the Agreement between Monaco and the European Union (Sovereign Order No. 11.682 of 4 December 2025)
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